CLA News / Gender-Based Violence Against Women and Girls in the Digital Age: Artificial Intelligence, Technology-Facilitated Abuse, and the Evolving Legal Response By CLA President Steven Thiru

21/09/2026
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When women and girls do have access to and use the Internet, they face online forms and manifestations of violence that are part of the continuum [sic] multiple, recurring and interrelated forms of gender-based violence against women.

— Dubravka Šimonović, Report of the Special Rapporteur on violence against women, its causes and its consequences on online violence against women and girls from a human rights perspective [1](2018)

Digital Innovation and New Dimensions of Harm

The rapid advancement of artificial intelligence (‘AI’) and the unprecedented accessibility of digital technologies have transformed modern life. AI now shapes how we communicate, work, learn, create, and solve problems, opening remarkable opportunities for progress. Yet the same technologies have also created new avenues through which longstanding forms of harm can evolve, intensify, and proliferate. Among the most pressing is technology-facilitated gender-based violence against women and girls (‘TFGBVAWG’).

While emerging technologies have created novel manifestations of abuse, their deeper significance lies in transforming the scale, speed, sophistication, anonymity, accessibility, and reach of gender-based violence. The legal challenge is therefore not necessarily to redefine violence, but to ensure that established legal principles continue to provide effective protection as the means of perpetrating harm evolve.

Many forms of gendered harm that once manifested predominantly in physical environments now increasingly permeate the digital sphere. Technology has amplified their reach, accelerated their dissemination, lowered the barriers to perpetration, and, in many instances, obscured the identity and accountability of those responsible.

These harms include online harassment, cyberstalking, image-based abuse, cyberflashing, non-consensual dissemination of intimate images, technology-facilitated coercive control, AI-generated sexual deepfakes, voice cloning, coordinated disinformation, and synthetic media. Their consequences extend beyond screens, producing psychological, social, economic, reputational, and sometimes physical harm, while undermining dignity, personal security, and women’s equal participation in public life.

International Recognition of Technology-Facilitated Gender-Based Violence Against Women and Girls

International organisations increasingly recognise digital violence as part of the broader continuum of gender-based violence against women and girls. The fact that abuse occurs through a screen does not diminish its seriousness. Generative AI can enable abusive content to be produced almost instantaneously[2], disseminated globally, replicated indefinitely, and preserved long after its initial publication, often through tools requiring little technical expertise. Its consequences frequently extend into victims’ professional lives, personal relationships, mental health, and physical safety.

The scale of the problem is reflected in international research. The Economist Intelligence Unit estimates that 85 per cent of women globally have witnessed online violence against women, while 38 per cent reported personally experiencing it and 65 per cent knew another woman who had been targeted. The study cautioned that these figures likely underestimate the true prevalence because many incidents remain unreported.[3]

The study further found that in 64 of the 86 countries assessed, law enforcement agencies and courts appeared to respond inadequately to online violence against women, while nearly three-quarters of respondents feared that online abuse could escalate into offline violence.

The problem is particularly acute for women in public life: 60 per cent[4] of women parliamentarians surveyed in the Asia-Pacific region reported online gender-based violence, while 73 per cent[5] of women journalists reported experiencing online violence in the course of their professional duties.

These developments raise a central legal question: can enduring legal protections for privacy, dignity, equality, autonomy, sexual integrity, and personal security remain effective as the technologies through which harm is inflicted continue to evolve?

Before considering the judicial response to these developments, it is first necessary to understand the principal forms through which TFGBVAWG is committed in practice.

Contemporary Forms of Technology-Facilitated Gender-Based Violence Against Women and Girls

In the digital age, TFGBVAWG has progressed from isolated online incidents into a systemic, pervasive, and ever more complex form of gender-based violence against women and girls[6]. As identified[7] by UN Women, by weaponizing data, creating realistic fabrications, and exploiting algorithmic loopholes, perpetrators have diversified their tactics, significantly expanding both the reach and impact of abusive conduct and making the internet a progressively more hostile environment for women and girls worldwide.

TFGBVAWG is no longer confined to offensive communications or isolated online misconduct, but encompasses a broad spectrum of behaviours. Some of the principal manifestations include the following.

  1. Disinformation, Cyber Harassment, and Gendered Online Abuse

Generative AI and digital media have accelerated the spread of targeted disinformation, misinformation, online harassment, and gender-based hate speech. AI-powered bot networks can rapidly reproduce defamatory narratives, misogynistic language, and coordinated harassment designed to intimidate and silence women participating in public discourse.

These effects may be compounded by algorithms that reinforce the ‘manosphere’[8] by promoting misogynistic content and deepfakes to receptive audiences. Existing safety mechanisms can struggle to detect evolving euphemisms, manipulated media, and coordinated abuse at scale.

Beyond active harassment, the architecture and deployment of AI may perpetuate[9] — and, in some circumstances, exacerbate — patriarchal norms, gender stereotypes, and existing inequalities. A major root cause is data bias[10], as analysis[11] of datasets used for training has revealed that women are disproportionately represented in domestic or caregiving roles, leading AI models to systematically reinforce these outdated tropes. The implication is clear: technological systems are not value-neutral; they frequently reflect and, in some cases, amplify the biases and inequalities embedded in the data, institutions, and societies from which they emerge.

When AI systems interact with the public without appropriate safeguards, they can quickly absorb and replicate societal biases, as demonstrated[12] by Microsoft’s Tay chatbot, which rapidly adopted misogynistic and offensive language after interacting with users, illustrating how AI systems can mirror and aggravate existing online toxicity.

2. Sextortion, Fraud, Impersonation, and Coercive Control

AI-enabled tools can aggregate scattered data from across the internet, allowing abusers to construct detailed profiles of individuals. This can erode the anonymity on which survivors of intimate partner violence and stalking may depend, facilitating blackmail, fraud, identity theft, impersonation, and coercive control.

Women in public-facing professions—including journalists,[13] politicians, lawyers, activists, and human rights defenders—may face AI-enhanced extortion or impersonation campaigns intended not only for financial gain but also to suppress professional activity, deter free expression, and damage credibility.

AI has also industrialised ‘catfishing’.[14] Bots can simulate realistic human conversations over extended periods, enabling perpetrators to cultivate trust, obtain sensitive information, manipulate victims, and arrange unsafe offline encounters. The distinction between digital deception and real-world exploitation is consequently narrowing.

3. Image- and Video-Based Abuse, and AI-Generated Sexual Content

Image- and video-based abuse represents one of the most harmful and deeply violating manifestations of digital violence, experienced or witnessed by 57 per cent of women in the EIU study[15]. Another extensive analysis[16] of over 95,800 deepfake videos found that 98 per cent of all deepfake videos online are pornographic, and that around 99 per cent depict women. These figures illustrate the overwhelmingly gendered nature of such abuse.

Free and user-friendly generative AI tools now require little technical expertise to fabricate convincing sexual images or videos using publicly available photographs. Once created, such material can be rapidly reproduced and redistributed, making complete removal practically impossible and inflicting profound violations of privacy, dignity, sexual integrity, bodily autonomy, and psychological security.

Image-based abuse has also become a potent weapon of gendered political violence.[17] Female public figures are disproportionately targeted with non-consensual sexual imagery intended to humiliate, discredit, or intimidate them into withdrawing from public life. Emerging research[18] suggests that such abuse may deter women’s political participation and distort democratic discourse.These harms are further compounded as virtual spaces further blur the line into real-world harm through disturbing simulations, including the digital rape[19] of women’s avatars on interactive platforms.

The harm extends far beyond reputational damage. Survivors may experience anxiety, depression, social isolation, professional consequences, and continuing fear that fabricated material may re-emerge indefinitely. Synthetic sexual imagery does not cause less harm because it is artificial; its consequences for victims are real.

4. Doxing, Digital Surveillance, and AI-Enabled Threats

AI technology has likewise significantly streamlined the process, and boosted the effectiveness, of ‘doxing[20]’ — the non-consensual online exposure of an individual’s identity or private identifying information, usually with malicious intent — and targeted online intimidation.

AI-assisted tools can aggregate information from public and private sources—including addresses, telephone numbers, employment details, family relationships, and location data—with unprecedented speed. The disclosure of such information can facilitate sustained harassment, stalking, and threats of physical violence.

AI can further personalise harassment by using tools like Natural Language Processing (‘NLP’) which allow it to analyse individuals’ public communications and identifying their vulnerabilities, enabling perpetrators to generate highly targeted threats at scale.[21]This algorithmic tailoring[22] can make psychological abuse more credible, intimate, and difficult to escape.

The sheer breadth and sophistication of these contemporary digital harms underscore a critical reality: many current legal and regulatory frameworks are fundamentally ill-equipped for an AI-driven world, as they were developed before the emergence of AI-generated content, automated bot networks, adaptive NLP-driven extortion, and large-scale synthetic media designed to evade standard digital safety guardrails. Although traditional legal principles remain highly relevant, their effective application requires legislative adaptation, technological expertise, and coordinated international cooperation.

As the boundary between online and offline harm diminishes, legal and regulatory responses must advance accordingly. Self-regulation and reactive criminal justice measures are insufficient on their own. Governments, regulators, technology companies, and civil society must work together to ensure effective prevention, accountability, and redress.

Judicial Responses to Technology-Facilitated Gender-Based Violence Against Women and Girls

Courts across jurisdictions are increasingly being called upon to apply established legal principles to changing forms of digital violence. Conduct once regarded as novel or uniquely technological has translated into familiar legal wrongs involving coercion, exploitation, invasion of privacy, extortion, reputational harm, and psychological abuse. The expanding body of jurisprudence demonstrates not only the adaptability of existing legal principles but also a growing judicial recognition that digitally facilitated harm may be every bit as serious as comparable misconduct committed through more traditional means.

The recent Australian case of Benjamin Jomaa[23] provides a significant example of sextortion. It concerned the use of artificial intelligence to fabricate sexually explicit images of women, which were then leveraged in attempts to extort genuine intimate photographs from them. In sentencing at first instance, Judge Kirralee Perry emphasized the seriousness of such conduct, and held[24]: “A clear message must be sent to the community that such deceit and disrespect will not be tolerated. . . . I do acknowledge the long-lasting consequences and impact of victims who have suffered violations, such as this, to their lives.

Also in Australia, proceedings[25] commenced by the safety Commissioner resulted in the Federal Court imposing a substantial civil penalty of AUD 343,500 plus costs on an individual responsible for creating and publishing deepfake images of prominent women online. The case marked a significant application of Australia’s online safety framework to synthetic image-based abuse, and signaled that civil regulatory mechanisms may complement traditional criminal enforcement in such instances.

In the United Kingdom, the Crown Prosecution Service successfully prosecuted[26] a 27-year-old man who used AI tools and genuine images of children to produce sexually explicit material. The case demonstrates how existing criminal offences can be applied to emerging forms of technology-facilitated abuse.

At the regional level, there is notable jurisprudence from the European Court of Human Rights (‘ECtHR’) that increasingly regards digital abuse as part of the broader continuum of violence against women.

  1. Volodina v. Russia (No. 2) (2021)[27]

In Volodina v. Russia (No. 2), the ECtHR recognised cyberviolence as an evolutionary extension of domestic abuse. The applicant, a Russian national, was subjected to a relentless three-year digital campaign by her former partner, who non-consensually distributed intimate photographs of her, tracked her location via hidden GPS devices, and created fake social media profiles to destroy her reputation.

Although domestic law enforcement possessed the legal tools to intervene, local police displayed an institutional reluctance to open a criminal case and conducted a slow, inadequate investigation that ultimately granted the perpetrator complete impunity. Upon review, the ECtHR ruled that the Russian state had violated Article 8 of the European Convention on Human Rights (‘ECHR’) (the right to respect for private and family life).

The landmark judgment established that a state’s positive obligations under the ECHR require the active, prompt, and diligent deployment of its legal machinery. Institutional inertia in investigating digital gender-based violence — or an inadequate investigative response — may itself amount to a direct violation of ECHR rights.

2. Buturugă v. Romania (2020)[28]

The critical nexus between cybercrime, data privacy, and intimate partner violence was examined in Buturugă v. Romania. The applicant filed complaints alleging that her former husband had physically abused her and illicitly accessed her Facebook account to copy her private conversations, documents, and photographs. Despite her explicit requests for a forensic search of their family computer to secure electronic evidence, domestic authorities dismissed the digital privacy claim, viewing it as entirely disconnected from the physical domestic violence complaint. The public prosecutor’s office eventually dropped the case with a trivial administrative fine, a decision upheld by domestic courts under the flawed assumption that social media interactions were inherently public.

The ECtHR overturned this rationale, finding that Romania had violated both Article 3 (prohibition of inhuman or degrading treatment) and Article 8 of the ECHR. The Court concluded that the investigation was fatally flawed because the state failed to acknowledge that digital violations, such as hacking and monitoring a partner’s correspondence, required investigation as allegations of domestic abuse.

The significance of Buturugă lies in its recognition that technology-facilitated abuse cannot be viewed in isolation when it forms part of wider domestic violence. The decision therefore underscores the need for law enforcement authorities and courts to adopt an integrated approach when investigating and responding to domestic violence in the digital age.

3. Khadija Ismayilova v. Azerbaijan (2019)[29]

The case of Khadija Ismayilova v. Azerbaijan highlights how digital extortion is weaponised as a tool of gendered political coercion to silence women in public life. Ms. Ismayilova, a prominent investigative journalist exposing high-level state corruption, was targeted in a sophisticated sextortion plot after receiving hidden-camera footage of her private sexual interactions alongside an anonymous threat to halt her work. When she refused to be silenced, the explicit videos were leaked online. Instead of executing an effective criminal investigation, Azerbaijani authorities restricted the victim’s access to her own files and aggressively worsened the harm by publishing an official status report that exposed her sensitive personal data.

The ECtHR found the state to be in violation of both Article 8 (privacy) and Article 10 (freedom of expression) of the ECHR. The Court ruled that the flagrant invasion of her privacy was deliberately linked to her professional work, cementing the precedent that states have a heightened positive obligation to proactively protect a woman’s journalistic freedom and free speech when digital humiliation is deployed to drive her out of the public sphere.

The ramifications of the decision extend beyond the protection of privacy. The case shows that technology-facilitated abuse can simultaneously engage the rights to privacy and freedom of expression, particularly where it is used as a tool to intimidate women and discourage their participation in public discourse.

Taken together, these cases demonstrate that TFGBVAWG is not developing in a legal vacuum. Courts are increasingly recognising that technology changes the means through which established wrongs are committed without diminishing the legal values requiring protection. Privacy, dignity, equality, autonomy, sexual integrity, personal security, and, where appropriate, freedom of expression remain central to the legal response.

At the same time, the jurisprudence illustrates the inherent limitations of adjudication. Courts determine liability only after harm has occurred, whereas AI enables abusive material to be generated, disseminated, replicated, and archived almost instantaneously. As Justice P. S. Narasimha of the Supreme Court of India has observed[30], the injury occasioned by AI-generated deepfakes may become widespread long before effective legal remedies or takedown mechanisms can be implemented. Judicial responses, while essential, represent only one component of a broader legal response. Comprehensive legislative reform, responsive regulatory frameworks, improved investigative capacity, greater platform accountability, and enhanced international cooperation are crucial to ensuring that legal protections adapt alongside technological capability.

Strengthening Legal and Institutional Responses

Given the scale, speed, and increasingly transnational nature of TFGBVAWG, this is not a problem that can be addressed piecemeal or left to individual responsibility. It demands a coordinated global response grounded in human rights, accountability, prevention, and international cooperation. In line with the growing warnings from the United Nations Committee on the Elimination of All Forms of Discrimination against Women (‘CEDAW’) working group on gender-based violence[31], the UN Children’s Fund (‘UNICEF’)[32] and other international bodies, there is an urgent need to recognise that digital violence is not a separate or lesser category of harm; it is an evolving manifestation of gender-based violence against women and girls that demands legal, institutional, and societal responses commensurate with its impact.

Five priorities are particularly important: modernising legal frameworks, strengthening enforcement, enhancing platform accountability, supporting survivors, and investing in prevention.

First, legal frameworks must evolve to address technology-facilitated violence explicitly. Many statutes predate generative AI and do not adequately address AI-generated harm. Reform should place consent at the centre, criminalise the creation and dissemination of non-consensual intimate content, establish clear accountability, and require appropriate platform responses. Stronger international cooperation is also needed to prevent offenders from exploiting jurisdictional boundaries.

Second, effective laws require equally effective enforcement. Justice systems must therefore be equipped with the expertise and resources necessary to investigate technology-facilitated offending. This requires specialised training for law enforcement officers, prosecutors, judges, and forensic practitioners so they can properly identify, analyse, preserve, and present digital evidence. Many systems are already struggling[33] with backlogs in digital investigations, which must be urgently addressed. Investment in forensic capability and international investigative cooperation will be essential if legal systems are to keep pace with offences that may be committed in one jurisdiction, hosted in another, and affect victims across many more.

Third, technology platforms must take greater responsibility for foreseeable harms occurring within the systems they operate. This requires transparent reporting mechanisms, effective detection, timely removal of unlawful material, meaningful cooperation with law enforcement, and regulatory accountability where systemic failures occur. Platform governance should complement, not replace, the rule of law.

Fourth, survivors must remain at the centre of every legal response and be supported through strong, coordinated care and assistance systems that recognise the seriousness of digital violence, which often produces profound psychological, reputational, professional, and financial consequences that extend well beyond the initial dissemination of harmful material. This means ensuring access to professionals who are properly trained to respond with sensitivity, empathy, and an understanding of how such abuse impacts survivors, rather than treating such cases as purely technical disputes or administrative complaints.

Legal assistance must also be accessible. Bar associations, law societies, and members of the Commonwealth Lawyers Association are uniquely positioned to expand pro bono initiatives, promote public legal education, and guide survivors through complex legal and digital processes.

Finally, prevention must begin before harm occurs. Digital literacy and online safety education should be embedded in schools, universities, workplaces, and professional institutions, with emphasis on consent, respectful online conduct, digital abuse, and available remedies. Lasting change will require a digital culture in which dignity, equality, and respect are treated as foundational norms.

Safeguarding Rights in the Digital Age

Violence against women has never been defined solely by physical acts. As documented in the United Nations Declaration on the Elimination of Violence against Women[34], it encompasses “any act of gender-based violence that results in, or is likely to result in, physical, sexual or psychological harm or suffering to women, including threats of such acts, coercion or deprivation of liberty, whether occurring in public or in private life”. This intentionally broad framing has endured because it is founded not upon the method by which violence is perpetrated, but upon the harm it inflicts and the inequality it perpetuates.

As technology continues to advance at an extraordinary pace, new forms of harm inevitably emerge in digital spaces. The various types of abuses discussed here are one such evolution, but they will not be the last. The tools, platforms, and methods may change — enabling abuse to be created, amplified, and disseminated with unprecedented speed, scale, and sophistication — yet these technologies have not altered the fundamental legal interests requiring protection. Privacy, dignity, equality, autonomy, sexual integrity, psychological security, and personal security remain the enduring values upon which our legal systems are built.

The challenge confronting legislators, courts, regulators, technology companies, and the legal profession is therefore to ensure that those principles continue to provide meaningful protection in a dynamic technological landscape. This is why the response cannot be confined to technological fixes alone; it must remain anchored in the foundational understanding that harm against women, whether physical or digitally constructed, is still violence, regardless of the means through which it is inflicted.

The Commonwealth has long demonstrated that its diversity of legal systems is united by a shared commitment to the rule of law, equal justice, and the protection of fundamental rights. Those shared values must now guide our collective response to technology-facilitated gender-based violence against women and girls. Innovation must never become a shield for impunity, nor should technological advancement diminish the protections that the law has long afforded to every person’s dignity and safety. Our responsibility is therefore clear: to ensure that technological progress is matched by legal progress, so that innovation serves humanity without eroding the rights and freedoms that the law exists to protect.

Only then can we say that justice has kept pace with technology.

Steven Thiru

President

Commonwealth Lawyers Association

24 September 2026

[1] Report of the Special Rapporteur on Violence against Women, Its Causes and Consequences on online violence against women and girls from a human rights perspective available on https://digitallibrary.un.org/record/1641160?v=pdf

[2] AI-powered online abuse: How AI is amplifying violence against women and what can stop it available on

https://www.unwomen.org/en/articles/faqs/ai-powered-online-abuse-how-ai-is-amplifying-violence-against-women-and-what-can-stop-it

[3] Measuring the prevalence of online violence against women available on https://onlineviolencewomen.eiu.com/

[4] 60% of women MPs from Asia-Pacific report online gender-based violence available on https://www.ipu.org/news/press-releases/2025-03/60-women-mps-asia-pacific-report-online-gender-based-violence

[5] UNESCO’s Global Survey on Online Violence against Women Journalists available on https://www.unesco.org/en/articles/unescos-global-survey-online-violence-against-women-journalists

[6] CEDAW working group on gender-based violence – Initial position paper on tech-facilitated gender-based violence against women available on

https://www.ohchr.org/en/documents/position-papers/cedaw-working-group-gender-based-violence-initial-position-paper-tech

[7] HOW AI IS EXACERBATING TECHNOLOGY-FACILITATED VIOLENCE AGAINST WOMEN AND GIRLS available on https://www.unwomen.org/sites/default/files/2026-01/how-ai-is-exacerbating-technology-facilitated-violence-against-women-and-girls-en.pdf

[8] Drinking male tears: language, the manosphere, and networked harassment available on https://www.tandfonline.com/doi/full/10.1080/14680777.2018.1450568

[9] Recommendation on the Ethics of Artificial Intelligence available on

https://www.unesco.org/en/artificial-intelligence/recommendation-ethics

[10] CEDAW working group on gender-based violence – Initial position paper on tech-facilitated gender-based violence against women available on

https://www.ohchr.org/en/documents/position-papers/cedaw-working-group-gender-based-violence-initial-position-paper-tech

[11] Generative AI: UNESCO study reveals alarming evidence of regressive gender stereotypes available on https://www.unesco.org/en/articles/generative-ai-unesco-study-reveals-alarming-evidence-regressive-gender-stereotypes

[12] Chatbots, Gender, and Race on Web 2.0 Platforms: Tay.AI as Monstrous Femininity and Abject Whiteness available on https://www.journals.uchicago.edu/doi/10.1086/715227#:~:text=Hours%20into%20launch%2C%20however%2C%20the,explore%20the%20role%20that%20Tay.

[13] Reports to police of online violence against women journalists double since 2020, with one in four experiencing related anxiety and/or depression available on

https://www.unwomen.org/en/news-stories/press-release/2026/04/reports-to-police-of-online-violence-against-women-journalists-double-since-2020-with-one-in-four-experiencing-related-anxiety-andor-depression

[14] AI-powered online abuse: How AI is amplifying violence against women and what can stop it available on https://www.unwomen.org/en/articles/faqs/ai-powered-online-abuse-how-ai-is-amplifying-violence-against-women-and-what-can-stop-it

[15] Measuring the prevalence of online violence against women available on https://onlineviolencewomen.eiu.com/

[16] 2023 STATE OF DEEPFAKES available on https://www.securityhero.io/state-of-deepfakes/

[17] Fact check: Female politicians hurt by sexualized deepfakes available on

https://www.dw.com/en/fact-check-female-politicians-hurt-by-sexualized-deepfakes/video-77264973

[18] Women in the age of AI-enabled disinformation available on https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI%282026%29782670

[19] Police investigate virtual sex assault on girl’s avatar available on

https://www.bbc.com/news/technology-67865327

[20] Online violence available on https://www.amnesty.org/en/what-we-do/technology/online-violence/

[21] Is AI creating new forms of violence against women? Available on https://www.unwomen.org/en/articles/faqs/ai-powered-online-abuse-how-ai-is-amplifying-violence-against-women-and-what-can-stop-it#:~:text=Sophisticated%20doxing%20campaigns%3A%20Natural%20Language,easier%20targets%20for%20doxing%20campaigns

[22] The Impact of Artificial Intelligence on Violence Against Women and Girls available on https://www.stimson.org/2026/the-impact-of-artificial-intelligence-on-violence-against-women-and-girls/

[23] Sinister, threatening, vulgar’: jail for sextortion available on

https://www.nine.com.au/australia-news/sinister-threatening-vulgar-jail-for-sextortion-20260425-p5zqze.html

[24] Sinister, threatening, vulgar’: jail for sextortion available on https://www.canberratimes.com.au/story/9232842/sinister-threatening-vulgar-jail-for-sextortion/

[25] Court orders $343,500 penalty for posting deepfakes of Australian women available on https://www.esafety.gov.au/newsroom/media-releases/court-orders-343500-penalty-for-posting-deepfakes-of-australian-women

[26] Man who used AI technology to create child sexual abuse images jailed available on

https://www.cps.gov.uk/cps/news/man-who-used-ai-technology-create-child-sexual-abuse-images-jailed

[27] Volodina v. Russia (no. 2) Available on

https://hudoc.echr.coe.int/fre#{%22itemid%22:[%22002-13397%22]}

[28] CASE OF BUTURUGĂ v. ROMANIA available on

https://hudoc.echr.coe.int/fre#{%22itemid%22:[%22001-201342%22]}

[29] CASE OF KHADIJA ISMAYILOVA v. AZERBAIJAN available on

https://hudoc.echr.coe.int/eng#{%22itemid%22:[%22001-188993%22]}

[30] AI Deepfakes Causing Irreversible Harm Before Takedown: Justice PS Narasimha Flags Legal Gaps available on
https://lawbeat.in/event-corner/ai-deepfakes-causing-irreversible-harm-before-takedown-justice-ps-narasimha-flags-legal-gaps-1581263

[31] CEDAW working group on gender-based violence – Initial position paper on tech-facilitated gender-based violence against women available on

https://www.ohchr.org/en/documents/position-papers/cedaw-working-group-gender-based-violence-initial-position-paper-tech

[32] CEDAW working group on gender-based violence – Initial position paper on tech-facilitated gender-based violence against women available on

https://www.ohchr.org/en

[33] Police forces overwhelmed and ineffective when it comes to digital forensics, new report finds available on  https://hmicfrs.justiceinspectorates.gov.uk/news/news-feed/police-forces-overwhelmed-and-ineffective-when-it-comes-to-digital-forensics/

[34] Declaration on the Elimination of Violence against Women available on https://www.ohchr.org/en/instruments-mechanisms/instruments/declaration-elimination-violence-against-women